CODING
Spine Procedures in ASCs CMS’ addition of some codes without others creates billing confusion BY KARA NEWBURY
I
n its ASC 2015 payment rule, the Centers for Medicare & Medicaid
Services (CMS) finalized the addition of the following nine spine codes as sepa- rately payable, effective January 1, 2015: 22551 (Neck spine fuse & remov bel c2), 22554 (Neck spine fusion), 22612 (Lumbar spine fusion), 63020 (Neck spine disk surgery), 63030 (Low back disk surgery), 63042 (Laminotomy sin- gle lumbar), 63045 (Removal of spinal lamina), 63047 (Removal of spinal lam- ina), 63056 (Decompress spinal cord). CMS also added two other codes to the ASC payable list, 22614 (Spine fusion extra segment) and 63044 (Laminot- omy, additional lumbar). These codes, however, are not separately payable
as they have been packaged with other codes on the list.
CMS included these procedures
after ASCA representatives made a presentation to its staff last year highlighting the safety and efficacy of these procedures when performed in the ASC setting. In addition, CMS agreed with ASCA’s assessment that CPT codes 22551, 22554 and 22612 were assigned to the wrong ambulatory payment classification (APC) group in the proposed rule and moved these codes to APC 0425, which has a higher reimbursement than
the group to
which they were assigned previously (APC 0208).
Spine cases are different from most other specialties performed in the ASC
setting because there are often multiple codes associated with one case. This raised questions among facilities as to how to bill for these procedures, since there were codes commonly performed in conjunction with the approved codes that were left off the list. For example, a spine surgeon might perform a medically necessary anterior cervical discectomy and fusion (ACDF) surgery (CPT 22551 and 22552), with morselized allograft (CPT 20930), application of intervertebral biomechanical device (CPT 22851) and anterior instrumentation two to three vertebral segments (CPT 22845) in an ASC. We heard from facilities indicating that 22552, 20930 and 22851 are routine components of the main code 22551, and that most surgeons often use the anterior plate with or without the cage in the performance of the core procedure. This raises questions and concerns regarding what to bill and how to bill for it. One question asked was “Would Medicare reimburse the ASC for CPT codes listed as covered procedures and deny only the CPT codes excluded from ASC payment or would the entire ASC claim be rejected since there were codes included that are not payable?” According to staff at CMS head-
quarters in Baltimore, listing excluded services on a claim with covered ser- vices would not typically result in a claim rejection; rather, a contrac- tor would deny only the lines that are excluded from payment in ASCs. It may be appropriate for the ASC to bill the beneficiary for facility charges associ- ated with the non-covered procedure(s). Others asked, “Assuming that Medicare pays for the reimbursable services, how should ASC services be submitted on the claim form in the example discussed above?”
28 ASC FOCUS OCTOBER 2015
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